Key Topic 4: Fees and expenses
AstraZeneca may engage a third party (including external stakeholders, health professionals and patients) for services if there is a genuine business need, but only to the necessary degree and only those third parties who are qualified and appropriate to provide the services. Examples include participation at an advisory board or steering committee, speaking at or facilitating meetings, or clinical and study related work.
The need for services and reasons for choice of service provider must be documented and stand up to scrutiny.
When external stakeholders provide services to AZ, a contract must be in place that covers remuneration. All transfers of value connected with provision of the service (including fees, accommodation, meals etc) must be documented for the purposes of disclosure, and must be in line with all applicable AZ policies and procedures as well as relevant local regulations.
Consider this example
In the US in 2014 the Department of Justice made some allegations that Teva and one of its subsidiaries made payments to a physician, Dr. Michael J. Reinstein, to induce the prescription of generic clozapine, an anti-psychotic medication.
It was alleged that the company agreed to pay Dr Reinstein $50,000 under a one-year “consulting agreement”, and allegedly also provided all-expenses paid trips to Miami for Dr Reinstein, his wife and several of his employees. Dr Reinstein quickly became the largest prescriber of generic clozapine in the country, and prescribed the drug for many elderly patients. Allegedly, the payments and other forms of remuneration from IVAX (the subsidiary) and later Teva Pharmaceuticals continued for many years, and resulted in the submission of thousands of false claims to the Medicare and Medicaid (insurance) programs.
The company agreed to pay $27.6million to settle the allegations.
